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JUSTIN SAMUEL'S 2000 GRAND JURY TRANSCRIPTS

Before the Federal Grand Jury
Western District of Wisconsin

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Testimony of:
JUSTIN SAMUEL
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Stenographic Transcript
of testimony taken before 19 members of the Federal Grand Jury of the Western District of Wisconsin at the United States Federal Courthouse, 120 North Henry Street, Room 260, in the City of Madison, County of Dane and State of Wisconsin, on Thursday, the 31st day of August, 2000, commencing at 9:43 a.m.

Appearances:
Office of the United States Attorney
By: PEGGY LAUTENSCHLAGER
United States Attorney, and
By: ROBERT ANDERSON
Assistant United States Attorney
City Station, Suite 200
660 West Washington Ave
Madison, WI 53701

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...MR ANDERSON: All right. The witness we're calling is Justin Samuel. Would you take the stand and be sworn in by the foreman, please?

THE FOREPERSON: Would you please stand and raise you right hand?

JUSTIN SAMUEL,
having been first duly sworn in by the foreperson of the Grand Jury, was interrogated and testified as follows:

THE FOREPERSON: Thank you. Please be seated.

EXAMINATION

BY MR ANDERSON:

Q Justin, would you state your name and spell the last name, please?

A My name is Justin Clayton Samuel. Samuel is S-a-m-u-e-l.

Q How old are you, Justin?

A I'm 21 years of age

Q What's your date of birth?

A December 31, 1978.

Q All right. And where is your original place of residence?

A Original place of birth or residence?

Q Both?

A I was born in San Jose, California, but I've lived mostly near Seattle in Washington. It's Snohomish, S-n-o-h-o-m-i-s-h, Washington.

Q Okay. A couple of things before we get started, and this is Peggy Lautenschlager - - excuse me, shouldn't have drank that - - the U.S. Attorney in our district, in case you never met her. I don't know if you have, and she's going to go through the substance of information you provided to investigators from the FBI last week and there will be some additional things. There's more details that we'll ask you about as well.
First of all, I want you to know as a witness appearing before a Grand Jury - - By the way, this is the Grand Jury, the people assembled to help us investigate federal offenses and eventually vote on Indictments, and after we're done asking questions, they'll have a chance to ask questions as well.
I also want you to understand that as a witness appearing here, you do have a right, if you have an attorney, to have that attorney outside and if at some point in time in questioning you want to ask your attorney a question, normally we would let you go outside to ask your attorney a question, but your not exactly mobile so we probably would let the attorney come in here and talk to you, if you want that opportunity, okay?

A Okay.

Q And you do have an attorney, right?

A Yes, I do.

Q That would be Mr Coffey, right?

A Correct.

Q In case you didn't know, he is outside available for you if you do have something you want to consult with him about, okay?

A Okay. Thank you.

Q The other right which witnesses normally have involves their 5th Amendment right to not incriminate themselves. But as you understand, and so the Grand Jury understands, you entered a plea yesterday to charges related to the events we are going to talk about. Do you understand that?

A That is correct, yes.

Q And you did enter the plea, right?

A Yes.

Q And therefore as to the events we are going to talk about, since you plead guilty to those, you really no longer have a 5th Amendment right. You waived that in entering the plea, correct?

A Correct.

Q Again, if you have any questions concerning that or anything, feel free to ask to consult with your attorney, okay?

A Okay.

Q All right. I'll turn it over to Peg now.

MS LAUTENSCHLAGER: I don't know if that's a good thing or bad thing, Justin. Good morning.

THE WITNESS: Good morning.

EXAMINATION

BY MS LAUTENSCHLAGER:

Q Okay. First I have a personal question to ask. Does one pronounce it vegan or veegin?

A Depends on the person. Different people, different ways.

Q There's no preferred pronunciation?

A No.

Q Okay. We'll move on then. Justin, as you know, we're here to talk about some events involving the release of mink at various mink farms across the country. Is that right?

A Correct, specifically relating to the Indictment made against me.

Q Right. Okay. And this Grand Jury actually has never heard testimony, have they?

MR ANDERSON: They did one witness

A GRAND JUROR: Back in April.

MS LAUTENSCHLAGER: Back in April, okay.

A GRAND JUROR: Nathan Brasfield.

BY MS LAUTENSCHLAGER:

Q Okay. That's right. They've heard just some testimony regarding the allegations that were in the original Indictment, so what I'd like to do is sort of walk through some of the information which you gave to Agent Strong the other day and some of the information which has come up in a previous Grand Jury, if that's okay with you?

A Okay.

Q Okay. Let's start with your time as a student at the University of Washington, and during that time, did you have an opportunity to me Peter Young and [name omitted by Peter Young Support Committee]?

A Yes, I did.

Q Okay. And how did you meet them?

A I met them through a student organization for animal rights.

Q Okay?

A Around campus.

Q Do you recall the name of the organization?

A Students for Animal Liberation.

Q Okay. Was that related to any other organizations involving animal rights group or was it simply a campus organization?

A It was an independent campus organization.

Q Okay. What sort of activities did that group get involved in?

A Mostly on University-related types of information distribution and protest of, like, ongoing campus things that were against the beliefs of the group.

Q And do you want to just briefly summarize the beliefs of that group?

A The beliefs of the group were mostly to the extent that animals should not be used for human purposes.

Q That would include not eating animals?

A That would include not eating animals.

Q Include not eating products from animals? That animal might be held in captivity, some sort of situation where they'd be milked or used in some way - -

A Correct. Correct.

Q - - for food products, and it would also mean that you wouldn't use animals for clothing items or things like that?

A That is correct.

Q What about research areas?

A The group is opposed to research. Any type of use of animals would just be against, like, them living their normal lives.

Q Okay. And these beliefs are ones which are probably commonly held by a lot of animal rights organizations, is that fair?

A I would say so, yeah.

Q Okay. And, indeed, one of the things that brought you together with Mr. Young and [name omitted by Peter Young Support Committee] was the fact that you all believe - - you all believe this?

A Correct. Correct.

Q Certainly at that time?

A I was a participant in this group, Students for Animal Liberation, yeah.

MR ANDERSON: So I have a reference, it just says when you were at the University of Washington. Can you tell me what year that would of been?

THE WITNESS: That would of been probably - - I was only at the University itself maybe from the summer of '96 to the spring of '97 maybe.

BY MS LAUTENSCHLAGER:

Q Okay.

A I think that was the time.

Q One year about?

A I had previous college education at the communtiy college before transferring there.

Q Okay. Now what sorts of activities would you do with Mr Young and [name omitted by Peter Young Support Committe] when it came to your involvement in that group on campus?

A A lot of things, such as distribution information, leafleting, going around campus and handing out information on vegetarianism or the testing done there, the research on animals done by the medical school of the University. Other - - other issues, too. Just general cosmetics testing in general, not specifically related to the University.
Also, every now and then a protest, if something was happening on campus. For example, if like on a specific day, like, just holding signs outside of the medical building where they do research on animals.

Q By and large it was protests, letting people know what your concerns were, that sort of thing?

A Yeah. Yeah, pretty much.

MR ANDERSON: Did you, when you were doing these things with them, did you discuss the ideas of the animal rights movement with Justin? I mean Peter Young and with [name omitted by Peter Young Support Committee]?

THE WITNESS: Yes. With a lot of other people, too; other people in the group, other people who weren't in the group. That was kind of the whole point was to discuss the issues.

MR ANDERSON: And you found your ideas matched with them? That's why you hung out with them more?

THE WITNESS: I guess our ideas matched. That's probably why we all ended up together in this organization and the group there.

BY MS LAUTENSCHLAGER:

Q When you had this qroup conversation, it sort of - - you all had this common interest and it was fun to get together and talk about these ideas and figure out what you could do, what you could - -

A Yeah. We all had interest in trying to just like raise awareness generally into, you know, promoting these ideas, so that what actually the whole purpose of the group was.

Q And among the members of the group, you became particularly familiar with Mr Young and [name omitted by Peter Young Support Committee] and the three of you sort of hit it off with a friendship? Is that a fair assessment?

A Yes. We became friends, yes.

Q Okay. During that time did you continue to explore animal rights issues and the various organizations involves in the advocating for these sorts of animal rights?

A Yeah. Yeah.

Q Okay. And in doing so, did you also check on things like the Internet?

A Yes, I would look at animal rights things on the Internet, too.

Q Are there a lot of sites involving animal rights?

A There's at least a couple I am familiar with, yes.

Q Okay. What sorts of sites are you familiar with?

A There's sites - - The Animal Liberation Front Information Service, which is just a service that provides kind of updates of things that have appeared in the news, that have been done on either - - related to the ideals of the people who, like, work on the Web site about what the ALF should do or whatever. But it's an informative kind of thing. like what to do if people are interested in these issues, the reason behind them, things that have happened in the past.

Q And - -

A There's other Web sites, too. There's other just kind of general vegetarian sites.

Q Is the Animal Liberation Front a part of PETA then, or was a part of PETA?

A I don't think so in any way.

Q Was it a membership type group?

A No. No. From what it says on the website, as far as I am aware of it, it says that any person who wants to do something in accordance with these beliefs of the people who set it out on the internet - - can claim themselves as part of the ALF or something. I don't think there is any tyoe of membership.

Q I know. For example, PETA sends out little fund-raising letters. I've received them in the mail and they tell me if I send $25, they'll continue to send me letters asking me for more money and send me little address labels or something like that. Does ALF do that sort of thing, too, or they're just simply informational?

A Not that I'm aware of, no. I think people can give money the information service, just like the supporter group that helps get information out about them. But from what I've read on there, I've never seen anything directly relating to the Animal Liberation Front. It's just a group of people providing information about the Animal Liberation Front.

EXAMINATION

BY MR ANDERSON

Q But as you stated, if someone commits an action consistent with the objectives or goals stated in the materials for the Animal Liberation Front, they can consider themselves a member of the group?

A That's how it states itself, yeah.

Q Okay. Did you eventually at a point in time when you engaged in actions consider yourself an arm or member of this group?

A No, actually I did not.

Q Did you - - The stuff on the Internet Web site, let me show you a couple of things. One of the things on the Web site would be a thing called, a document called The Final Nail, right?

A Correct.

Q You had seen that before, hadn't you?

A Yes.

Q Let me ask you this. When you say you had looked on the Web sites, did you have a computer of your own? Did you use someone else's computer?

A I had a computer of my own. I used the University computers, parents' computers, friends' computers, just whenever I wanted to use one.

Q Okay.

A Whatever was available?

Q And did the materials that were on the Web site, did you share the information form those materials or print off materials and share them with Peter and [name omitted by Peter Young Support Committee]?

A They would probably see them independently, too. I don't know if we discussed them. I think we probably had other copies, not from the Internet, just around as part of information, just among the mass of different kind of animal rights information through - - giving to people if they were interested.

Q In addition to being available on the Web site, when you attended rallies or meetings or something, did they have copies of The Final Nail available?

A Yes. Sometimes I had seen them, different types of like, information like stalls, information stalls, a stand.

Q And had you, if not looking for the documents with Peter and [name omitted by Peter Young Support Committee], had you at least discussed the ideas that are expressed in the Final Nail about, toward mink farms in particular?

A Yes, we have.

Q Okay. One of the things that, in addition to - - By the way, Peg had placed in front of you Grand Jury Exhibit No. 1. Just looking at that, it has a Web site www.envirolink.org/alf/articles. Is that Web site familiar to you?

A Yes it is.

Q Okay. And looking at this document, and this was from the document index or chronometer or whatever you would call it. Looks like it was printed in December of 1996. Has an article Many Faced of the Fur Industry, The Fur is Dead; listing types of animals; chinchilla, fox, mink. Listing farms in various states, including Wisconsin. Has an article Free at Last and Maximum Destruction, Not Minimum Damage. Released Mink Can Survive in the Wild.
Had you seen these articles before?

A Yes. I'm sure I read the whole thing probably.

Q Okay. Now, in these articles, and then there is also for the same Web site, this is Exhibit No. 4, www.enviroweb.org/alfis, which is the Animal Liberation Front Information Service, is that right?

A Yes.

Q Is that what you were talking about earlier in terms of news?

A Yes.

Q This has a listing on this particular page, this exhibit, Animal Liberation Front Guidelines, and had you read the guidelines of the Animal Liberation Front before?

A Yeah. Yeah, I have. I'm assuming they're the same ones written here, yeah.

Q It lists, To liberate animals from places of abuse, i.e., laboratories, factories, farms, fur farms, et cetera, and place them in good homes where they may live out their natural lives free from suffering.
Second objective; inflict economic damage to those who profit from the misery and exploitation of animals.
Next, to reveal the horrors and atrocities committed against animals, and it goes next, to take all necessary precautions against harming any animal, human or nonhuman.
Next, any group of people who are vegetarians or vegans and carry out according to ALF guidelines have to right to regard themselves as part of the ALF.
And, finally, the Animal Liberation Front consists of small, autonomous groups of people all over the world who carry out direct action according to the ALF guidelines.
Are those all familiar to you?
A Yes, they are.

Q Okay. So one of the objectives of the Animal Liberation Front is not only to free the mink, but to try and stop the fur industry, correct?

A That's correct.

Q And so to achieve that objective, to make it not profitable for the mink farms to operate, economic harms to the farms is advocated, right?

A Yeah. It appears to be, yes.

Q And, in fact, when you decided to go out and commit the actions you committed, did you commit those actions with the ideas of those objectives in mind?

A I understood those would probably be definite side effects, but my primary motivation at the time actually really fully related to saving of the lives of the individual minks.

EXAMINATION

BY MS LAUTENSCHLAGER:

Q Justin, if I might ask, essentially what happened is somewhere along the line while living with Mr Young and [name omitted by Peter Young Support Committee], you and Mr Young decided that you were going to travel across country and figure out where some mink farms were and release as many mink as possible, is that fair?

A That's fair.

Q And you were kind of on your way to Florida because once you got there, after you released all these mink, you were going to hang out on a beach like any other kid who's 19 or 20 is anxious to do. Is that fair?

A That's correct.

Q And when you do this, in part you want to release the mink and make sure that they're set free. Would that be - -

A Yeah. The idea was to give then the best chance of surviving as possible.

Q Okay. And, but, in doing so, do you think you could have figured out, I mean, the way in which you did it, you essentially came with barbed wire cutters, cut down portions of fences, outside fences and went into the barn type structures in which the mink were kept, correct?

A Correct.

Q And then you would take off the back portions or whatever of the cage?

A Open the cages.

Q Open the cages, tip them over and let the mink run free?

A Correct.

Q Did you assist the mink in getting out of the cage?

A No. They tended to leave, almost all of them immediately. Some of them were, like, curious for a few seconds first, but I think they just - - It's just a very small cage and being curious animals, only one direction to go outside of the cage, so they tended to leave on their own.

Q Kind of mean animals, too? Particularly when held in captivity?

A I don't know. I think they probably don't have a very - - very much love for the people because of their, like negative interactions with them their whole life, but they weren't like trying to attack or vicious. If they felt threatened, like your hand is next to them in the cage, they'll bite you, but - -

EXAMINATION

BY MR ANDERSON:

Q Can I clear something up? I'm sorry. Let me clear something up about that, when you released the mink. In your statement to the investigators last week, you said when you released the mink out of the cages, you had cut down the perimeter fence ahead of time, correct?

A Correct.

Q Then you released the mink from the cages and once you had opened the cages, you got out of there quickly, you and Peter, right?

A Yeah. Correct.

Q So if the mink were milling around the farm, not going out of the fence, you just got out of there anyway, right?

A Yeah. Correct. But we would cut down the fences outside ahead of time to kind of aid them in being able to get past the fence.

Q If they found their way out that fence, so you didn't take time to shoo them out?

A No. Probably for various reasons, one just being time and the idea that maybe more would find their way out if all of them had a chance to run around individual going across the fence.

EXAMINATION

BY MS LAUTENSCHLAGER:

Q Did you do much research prior to this in terms of the likely survival for these minks if they were to be released?

A Some things. Like, there was an article in there, The Final Nail there, and there's probably other articles on the Internet and I had read things such as this here, No Compromise. Going to go through, and that probably talks about that, too so - -

MS LAUTENSCHLAGER: No Compromise, just for the record, No Compromise is marked as Grand Jury Exhibit 3?

MR ANDERSON: Three

MS. LAUTENSCHLAGER: Is that correct?

EXAMINATION

BY MR ANDERSON:

Q You've heard of No Compromise before?

A Yes, I have.

Q Correct me if I'm summarizing wrong. It's sort of a newspaper, news article magazine or magazine on animal liberation?

A Correct.

Q Does it have different issues occasionally, or - -

A Yeah. It talks largely about things like protests, from what i remember right. I haven't seen any, like, recent copies in a long time, but I had seen that one before.

Q That particular one?

A Yes. But it talks about everything, the issues of liberating animals, issues of the demostrating, things to talk about. Likewise to distribute information. Like events to go to.

EXAMINATION

BY MS LAUTENSCHLAGER:

Q Is it fair to say that one of your goals was to make sure that in ideal world, that there will be no more mink farms?

A I think that's fair to say. That was part of my beliefs.

Q Part of you actions were to make sure that we don't keep having mink farms around, is that fair?

A Yeah, I think.

Q Put them out of business?

A I think my vision of the ideal world definitely would have been without mink farms.

Q And at the time you left, your thought was kind of like these actions would in part help achieve that ultimate ideal goal? Is that fair?

A Definitely, yeah. Yeah.

Q Okay.

EXAMINATION

BY MR ANDERSON:

Q Because the farmers were, whether the mink got out, escaped or not, the farmers were aware that there was someone out there that could take action against them that would cause increased security costs for the farm? They'd have to increase their cost of producing the mink and that that might drive them out of business?

A Well, these are definitely issues that were, that are discussed as part of the idea of liberating mink. But once again, different people - - I mean both people who, like, just like people on the street, I would talk to other people in these organizations, would just have different opinions on their own priorities on what was important, whether it was like the individual mink in the cages or whether they were concerned about more abstract economic things.

EXAMINATION

BY MS LAUTENSCHLAGER:

Q Did you talk to Peter at all about what was motivating him to go?

A He - - I don't know if his beliefs would be exactly the same as mine, but I guess, I mean, from my understanding, I guess it would be fair to say that it was just kind of maybe most people's beliefs that I spoke to who believed in the idea that in an ideal world, there shouldn't be mink - - Some sense of understanding of all the different issues.

EXAMINATION

BY MR ANDERSON:

Q This is beyond protests, what you guys were doing? This is what is called direct action, right?

A Correct.

Q Direct action means affirmative, physical use of some sort of action against an animal-producing or animal-using industry, right?

A You say against, but it might be - - Actually the terms "direct action" might be taken as direct action for an animal. Not saying against an industry.

Q Getting back to when you released the mink and weren't so concerned about scooting them out, but getting out quickly, was it also, from reading the materials you had also known to you, that once you released the mink from those cages, there was a loss of value of any mink that were breeding mink?

A I was aware of that, but - - but you said I was concerned about scooting out quickly. That also came as a desire not to get caught. I was aware that what I was doing was illegal and there was the concept that if you - - if you get caught, you can't go to the next farm the next day.

Q Not just illegal, but these farmers wouldn't be too happy with you?

A It's probably not the safest to be found either, so - -

Q Right. Right. You understood once you released the mink from their cages, even that action, from what the material advocates, does some harm to the mink farm in not being able to tell which breeding mink are which?

A Yes. I was aware of that.

MS LAUTENSCHLAGER: Let me - -

MR ANDERSON: Okay.

EXAMINATION

BY MS LAUTENSCHLAGER:

Q: Let me get back to you guys hit the road. [name omitted by Peter Young Support Committee] opts out of coming with you. Is that fair?

A I don't know about opts out. [name omitted by Peter Young Support Committee] just wasn't interested from the start. I don't know exactly what [her/his] feelings were. [omitted] just, when the idea was presented to [omitted], the idea of driving to Florida, while on the way stopping through various mink farming states in the Midwest and releasing mink, just for [omitted] own reasons - - I don't know what those were, if it was like legal or personal or beliefs - - [omitted] just was not interested in coming.

Q [Question omitted by Peter Young Support Committee]

A I don't know exactly.

Q You don't know. But later when you ended up in, near Sheboygan, Wisconsin and needed a bus ticket, you knew to call [name omitted by Peter Young Support Committee] out there?

A Yeah, so [omitted] must have - - I don't know if I knew [omitted] plans, but I guess I must have known [omitted] was going out there and [omitted] given me a phone number, so in that case, I guess I probably did know. I'm not sure if it struck me as that big of a deal at the time, but - -

Q So the two of you go out. You've got the red Geo Metro and that red Geo Metro is in [name omitted by Peter Young Support Committee] name?

A Correct.

Q And it is owned, though, by all three of you? You ante up a third of the money, or approximately?

A Approximately a third. I'm not sure if it worked out exactly, but - -

Q [name omitted by Peter Young Support Committee] said, Go ahead, use the car, but I'm not going with you?

A Yeah. Yeah. It was kind of from the standpoint, even though the title was in [omitted] name, like [omitted] wasn't really the sole owner of it. It was jointly owned. So the two of us wanted to use it. [omitted] was - - We wanted to know if [omitted] wanted to come along at that time. [omitted] didn't need it, use of it, so - -

Q So - -

MR ANDERSON: Did any - -

BY MS LAUTENSCHLAGER:

Q Well, during this time, though, you were not sure that you remembered [omitted] was going out east at the time you left?

A See, I - - It was just a question I wasn't, like, thinking about, but I guess I must have known because I remember I did have the phone number, like how to contact [him/her].

Q So you had it when you left?

A Yes. Yes.

Q Okay.

EXAMINATION

BY MR ANDERSON:

Q How much did each of you kick in for the car?

A I don't know. I think around $700.

Q A piece?

A Yeah.

Q Tell me this. Before you bought the car, did you have a job?

A Yeah. I worked at different places. I had worked at a fast-food restaurant before. I had worked at an engineering firm. I had worked at a supermarket.

Q What about Peter?

A I'm not sure about him.

Q What about [name omitted by Peter Young Support Committee]?

A I believe [omitted] had a job at [omitted].

Q Okay. So the money that was used for the car, where did you get your money from?

A My money?

Q Yeah?

A It came from previous savings, and also because I was a student I wasn't always working, my money was also combined with money like I was getting from my parents from just living off of, so it was a combination of savings or money I had saved and not spent while my parents were helping me live as a student. So, but the breakdown of, like, what part of what, I don't know.

Q When the car was seized in Sheboygan and then held, why didn't you try to get the car back after the police were done with it?

A Well, from my part, I wasn't interested exactly in showing up there soon afterwards because I didn't know, like, my legal status. So I wanted to get better legal information, and I think - - I don't know for [name omitted by Peter Young Support Committee] part. I don't know if [omitted] was very interested in going because maybe a cross between not needing it and not being - - [omitted] not having that much money invested in it and maybe not knowing the legal ramifications, too, and if it was being held as, you know, evidence or something. But that's just conjecture. I don't know.

MR ANDERSON: Okay

EXAMINATION

BY MS LAUTENSCHLAGER:

Q Lets go to the first mink farm that you went to. That was one you remember fairly vividly?

A The name of that?

Q The one in South Dakota. There was a mink farm in South Dakota and you indicated Watertown, South Dakota?

A Okay. Yeah, I believe that was mink and fox.

Q I believe it might of been, yeah. I think so. And it was one that took a while for you, is that correct?

A Yeah, that's correct.

Q Okay. And this is the first one you hit and you had some memories of it because it took a while, is that correct?

A Yes, that's right.

Q Okay. I think you reported to Agent Strong that it was about three hours it took you guys to complete it?

A Yeah. At least, yeah.

Q And at that time it was you and Mr. Young?

A Correct.

Q Who went there? No one else?

A No one else?

Q Is that correct? Okay. And you cut the holes in the perimeter fence and released mink and maybe fox? You're not sure?

A I believe there were fox there. If I told him I wasn't sure about fox, it was because I couldn't remember if that was the farm that had fox. But I think there was one farm with fox and so that was probably it, yeah.

Q Okay. But, and these raids kind of blur together in your memory after a while?

A Yeah. I visited like a week and a half or something like that. It was just different farms, not knowing the area.

Q Do you know about how many you hit during that time?

A Somewhere around maybe six.

Q Okay.

A I was mostly relying on the Indictment to tell me the exact numbers. I don't know if it was seven.

Q Okay. And by and large you ended up executing these raids on farms in South Dakota, Iowa and Wisconsin, is that correct?

A Correct.

Q And you picked the Midwest because of concentration of mink farms?

A That's correct.

Q Indeed, I've discovered Wisconsin has an inordinately high number of mink farms. Is that fair?

A Yeah. Yeah, I think so.

Q And some of these were actually on the western side of Wisconsin, is that correct?

A Yeah. Yeah.

Q Then you went to the eastern part of Wisconsin geographically.

A That was probably the route we took. We were traveling that direction so - -

Q Between South Dakota and Wisconsin, you also made a stop or two in Iowa?

A Correct.

Q Okay. Now during these times you relied on an atlas, is that correct, to find your way around?

A I don't know if it was an atlas or various maps. We had at least two, but - -

Q Do you recall telling Agent Strong that you stopped off oftentimes at the Barnes and Noble bookstore because then you could do some reading while you were there before buying the maps?

A Yeah. Yeah, because we would have to get the maps in, like, detailed outlets. If we had a big road atlas, I wouldn't have detail to go down and finding individual places.

Q Do you remember stopping at the Barnes and Noble in Omaha, Nebraska?

A I don't remember that one individually, but probably did, so - -

Q And you purchased those bolt cutter tools, did you do that along the way or did you use the same bolt cutters. or - -

A We had - - I know we at least probably changed the bolt cutters once, but we did repeatedly use some of them.

Q But you did have a number of bolt cutters and not just the same set?

A Yeah. I think at least once maybe we had thrown them away.

Q Okay.

A But - - But I think we tended to, especially later on, like after the first few days, just keep - -

Q They were getting a fair amount of use or were they just cheap bolt cutters?

A Probably both. We were, you know, using them and they were probably cheap too.

EXAMINATION

BY MR ANDERSON:

Q I'm sorry. Does one of the things that, the materials that you've read from the animal version advocate that you not reuse things that can tie you to event?

A Yeah. I think that's information that's probably in The Final Nail, I would guess.

Q Did that factor in throwing away bolt cutters, getting new ones, too?

A I don't know if the idea came from there originally, but the general idea was knowing that they could be linked to you like - - like analysis of the prints and - -

Q Tool marks?

A - - the tool marks, yeah.

EXAMINATION

BY MS LAUTENSCHLAGER:

Q Before you get to one of these or when you first get to one of these farms, do you do a bit of surveillance, is that fair?

A Yes.

Q You checked out to make sure there weren't large fences or dogs or things like that that might impede you in your mission. Is that fair?

A That's correct. We would look for, like, a place to park and just like, just kind of get an idea of the layout of the place.

Q Okay. You were using a list from the Final Nail of mink farm locations?

A That's correct.

Q And then you would make notations in your Final Nail copy of these farms and information about the security, correct?

A Yeah.

EXAMINATION

BY MR ANDERSON:

Q Let me ask you, did you have, when you went and you were using this list, these various places, did you have any prior reconnaissance information from other people that had been involved?

A No. We just had a list of addresses and it was kind of hit or miss as to whether we actually find them, like because not knowing the area and not - - the addresses, I don't know if I had the impression at the time that whoever made the list probably had never been there. They maybe had just gotten the addresses from some, I don't know, list of businesses or something, but - -

Q And the notes that were made on the list were made by?

A Those were made by Peter.

EXAMINATION

BY MS LAUTENSCHLAGER:

Q Okay. Peter was the driver during that time, correct?

A He drove because I didn't know how to drive stick, so - -

Q Okay. Now despite your lack of memory of specific farm sites, as you mention, they all sort of blur together, you do have some recollections, however, of various incidents which took place during this trip through the Midwest, is that fair?

A That's correct.

Q And among those recollections would be your recalling having your car towed from a ditch that was near a fur farm in Iowa. Do you remember that?

A That's correct.

Q What happened with the car, do you remember?

A How it got stuck or afterwards?

Q Yeah?

A How it got stuck. I think we were maybe a few miles from a fur farm or looking for one and then we were kind of off a main road and, like, a farming area and we were trying to turn around in an intersection, and there was some, like, bushes and it looked like solid ground maybe or something, but the back tire got stuck and we had to have it towed out.

Q Okay. Did you call a tow truck?

A Yes, we did.

Q Okay. Did you communicate with anybody other than the tow truck driver that day?

A Maybe just like a farmer nearby. Not a mink farmer but just a person who owned a nearby farm asking them if they could help pull us out of the ditch, but I don't think he wanted to just because maybe legal things, not wanting, if he damaged our car, if we would be mad at him, so he told us we'd be better off calling a tow truck.

Q You did that then?

A Yeah. Yes.

Q Again this entire time, it's you and Peter Young?

A Correct.

Q Okay. And then do you recall being in western Wisconsin and being interviewed by a policeman at a minimart?

A Yes, I do.

Q Okay. What were you doing at the minimart, do you recall?

A I think we were just reading and maybe it was nighttime and there was lights in there and so we were eating dinner, using, like, hot water and the microwave to heat up some food.

Q Do you recall what part of the state you were in?

A No. No, I don't.

Q Okay. And you were - - Were you in that location as a result of checking out some fur farms?

A Either we were crossing through from one of the previous places and another, or there was a fur farm nearby. One of the two, but - -

Q Okay. Do you recall what the nature of the conversation of the policeman was that night?

A I think he was mostly just wondering what we were doing there, like two kids from Washington, you know, in his, like, town and asking us where we were going and - -

Q You had Washington plates on the vehicle - -

A Yes, we did.

Q - - at the time, too, and this was a small town?

A Yes, it was.

Q Okay. And then do you recall as well running into an Amish farmer in Wisconsin?

A Yes, I do.

Q And was that near the site of a fur farm?

A Yes. I believe it was somewhere near by. I think we were parking the car to get out of the car to go maybe look around on foot, just kind of walk down the main road.

MR ANDERSON: Do reconnaissance on the farm?

THE WITNESS: During the day, to see like what we thought of the place.

BY MS LAUTENSCHLAGER:

Q Okay. Did you talk with the Amish farmer at all?

A Yes. I don't know if we were walking away from the farm, but at some point we got his attention and he told us we were on private property. We had to leave, and so we left.

Q Did you do a raid on the fur farm that was nearby?

A I don't believe so.

Q Do you also recall having contact with a state trooper for making an illegal turn while you were in Wisconsin?

A Yes, I do.

Q And do you know what the circumstances were surrounding that?

A I don't know if it was just we made a U-turn and in some city we didn't know and, like, just not knowing the streets or maybe turned, like, the wrong way down a one-way street or something, but it was a minor traffic violation and I don't think anything more than a citation was, or, like a warning, not a citation. Just don't do it again kind of thing.

Q Okay, And, now, when you had these circumstances where you run into two members from law enforcement and these various farmers and whatever, did that in any way dissuade you from continuing on with the mink release or - -

A Maybe it played some part, but at the time, for myself, I just - - it was kind of just there was a feeling of just wanting to go out and, like, there is these mink in cages and I didn't want them to be there and I knew they were going to be slaughtered for their fur soon and it was kind of like this feeling of maybe making a sacrifice for them. And so that was kind of what was driving me was just this feeling of, it wasn't exactly by the safest, the way that I thought of doing things.

Q You knew the pelting season was coming up?

A That's correct.

Q Winter was soon to be there?

A That's correct.

Q Okay. I don't think we've ever asked you about time frame. Do you recall the time frame, like when you left on this trip and when these releases started?

A I left sometime in early October.

Q Okay.

A And to tell you the truth, the estimate here is made really from the Indictment because I wouldn't remember dates, but, because I've been looking at the materials I've had legally so long, I could tell you it started like the 16th through the 23rd or something.

Q You could pretty much say with certainty it's the fall?

A Yeah. Yeah.

Q In what year?

A In 1997.

Q Okay. Now at some point, though, as you're going to all these fur farms, you end up in Sheboygan County where you're looking at a fur farm, is that correct?

A That's correct.

Q And during that time you ended up with contact with the police in terms of a search of your vehicle, is that correct?

A They didn't search it immediately. They seized it, they said on the grounds of getting a search warrant. That's correct, yeah.

Q Right. And they eventually obtained a search warrant?

A Yeah, I found out later.

Q Now, when they seized your vehicle, what did you do with the vehicle?

A Peter and I were given the option of, by a state trooper, we could either stay there, he could drive us to the station or he could drive us into the town, which I guess was Sheboygan, and just drop us off there because we didn't have a car.

Q Okay. When you were stopped and the vehicle was seized, you were in Oostburg, Wisconsin. Does that sound familiar?

A That sounds familiar.

Q Okay. That's near Sheboygan and, indeed, then they took you to Sheboygan, is that correct?

A Yeah. It was either Sheboygan or Oostburg. I don't know the towns, but it was a town that had a larger, like a gas station and, like, a motel or something and some - - I don't know if it was Oostburg or Sheboygan, but - -

Q And once you were taken to the town, what did you do?

A The first thing we did was I called [name omitted by Peter Young Support Committee].

Q Okay.

A And I told [omitted], like, the car got taken away and I don't - - I don't think anything more needed to be said than that, and [omitted] must of inferred like what Peter and I had been doing.

Q Okay. Well, [omitted] knew when you left that you guys were going to release mink, fair?

A I don't know if it was - - See, there was never, like, definite plans made, but I would guess [omitted] was probably certain we were going to go, you know, do something like that.

Q So when you called [omitted], it's your assumption that [omitted] knows the car has been taken away? You need to get out of there?

A Yeah. That was my assumption. I remember that's kind of how the phone call went.

Q Probably trouble ahead, so might as well get on the next bus to wherever?

A That's correct. I didn't have money for the bus.

MR ANDERSON: [Omitted by the Peter Young Support Fund] didn't ask you a lot of questions because [omitted] knew that, basically, what would happen if you got caught?

THE WITNESS: Yeah. [Omitted by the Peter Young Support Fund] was probably aware that we were doing something illegal related to releasing mink and so [he/she] had no interest in knowing the details.

EXAMINATION

BY MS LAUTENSCHLAGER:

Q Do you recall if you called collect or called on a calling card?

A I don't recall, but - - I don't know. Obviously didn't have enough, like, change because, you know, money to the east coast, so it was either collect or calling card or both. I don't know.

Q So you made the call to [omitted by the Peter Young Support Committee] and what did [omitted] tell you?

A [Omitted] told us that we should - - [omitted] would get us a bus ticket for us and that we should pick up the bus ticket.

EXAMINATION

BY MR ANDERSON:

Q Question omitted by Peter Young Support Committee

A That's what I've been told. I at the time - -

Q Didn't know that?

A That's what the FBI agents and the proffer told me, but at the time, that was just the number I had for [him/her].

Q Lets make sure this is clear because there’s a couple places in the statement that you're talking about [name omitted by Peter Young Support Committee] and I'll tell you what the reports says here initially. Samuel stated - - this is before you went on the trip - - Samuel stated that he and Young had planned to take the car across country to visit Florida, and along the way they would hit a few fur farms to release mink. Samuel stated he'd visit Florida, relax on the beaches. Samuel stated that this plan was discussed with [name omitted by Peter Young Support Committee], but [omitted] stated [she] was not interested in getting directly involved with the release of these animals. Is that correct?

A That sounds correct.

Q Samuel stated that he, Young and [name omitted by PYSC] had general discussions about their previous involvement in the animal rights movement and [omitted] gave them consent to use the car titled in [omitted] name to take this trip.
Is that right, you discussed your prior involvement in animal rights and [he/she] said, Go ahead and use this car for this trip?

A See, as far as the way it worked, that's - - that's maybe one way to put it, but I don't know if it is misleading because the way we saw the car was just jointly owned it with - - It wasn't, This is my car and you can use my car to do this. It was just kind of, look, you don't need the car. We want to take this trip and it's our car, too. And [omitted] is like, I don't need it and I don't have an interest in coming. That was more to the point. You can - - You can phrase it like that that from a title ownership

Q To the extent [omitted by the PYSC] had ownership interest in it, [omitted] allowed you to use [omitted] ownership interest for this trip?

A Yeah. [omitted by the PYSC] had no - - no use for the car at the time, so [omitted] was not concerned with us using it for whatever purpose, whether it be to travel or releasing mink. It was just [omitted] didn't have a need for it.

Q And in planning this, you got - - you got the fur farm list? Peter went and got some other addresses of fur farms from the library or some other source?

A I don't know where they came from, but probably the library I think, yeah.

Q And so when you started out on this trip, although you say your ultimate objective was Florida, it was intended to be part of the trip that you hit these mink farms and release mink, right?

A Correct. That was part of the plan Peter and I had, was that it wasn't just one or the other. It was this kind of - - It was a dual-purpose trip. It wasn't just a trip to Florida and it wasn't just a trip to go release mink. That we also wanted to travel and so - -

Q And it's those plans you also discussed with [name omitted by PYSC] and tried to encourage [omitted] to come along, right?

A I don't know about - - I don't know if it was, like, forcible encouraging. I don't know, but - -

Q You asked [omitted]?

A We asked if [omitted] would be interested and I don't know how indirectly because there is kind of a thing where, you know, you don't know, like, what people really think about, you know, what people think about these things happening. But you don't know what people think about being more closely involved, this kind of thing, and so you're kind of concerned about asking someone. I don't know how indirect the asking was, or how indirectly.

EXAMINATION

BY MS LAUTENSCHLAGER:

Q The three of you are living together at the time, is that correct?

A No. No. No, not - -

Q You weren't in the house at the time?

A The house?

Q Mercer Island.

A That was shortly - - a short period thing so - -

Q [Omitted] knew you were going? And by and large knew the purpose of your trip and - -

A Yeah. I would say [omitted] generally knew that we had plans of releasing mink, but as to whether, like, you know, how - - how directly we laid out for [omitted], like what we were going to do, I don't know. Kind of concerned indirect conversations maybe Peter and I had with [him/her].

Q Is it fair to characterize this as not that you all sat down and had a single conversation saying this is what we are going to do and these are the farms we hope to hit, et cetera, but, instead, during the course of your regular contact with one another, things came up like, well, we're going next week. You sure you don't want to come along? Something like that, where things would come up incidentally within the course of regular conversations? Is that a fair characterization?

A Well, see, it's been a couple of years, first of all, and I would also assume - - I guess my point here is I don't know how direct the conversation we ever had. Maybe they were - - Definitely it wasn't never known, like, what farms, or, you know, what states or things. It was just kind of this general plan, we think we want to do this and we're pretty sure we want to do this and we want to go out and see how it works. We don't know what it's going to be like, so - -

EXAMINATION

MR ANDERSON:

Q But you definitely had a plan to attack fur farms, although you didn't discuss details? You didn't plan out details, this one we're going to hit, that one we're going to hit, you didn't plan that, right?

A No, Peter and I had - - By the time we left, we were definitely sure we were going to mink farms in the Midwest.

Q That's what you told [name omitted by the PYSC] you were going to be doing on the trip?

A I don't know how directly we stated where we were going or these kind of things, but I think it was made clear to [omitted] that our interest was into, like, if [omitted] wanted to come, we would like [omitted] to come and help us.

Q [Name omitted by PYSC] statement was to you, correct me if I'm wrong in paraphrasing this, was [he/she] didn't want to be that directly involved, right?

A I don't know - - I don't know if that's a proper paraphrase. I think - -

Q How did [omitted] put it?

A I think it was like - - [omitted] really didn't want to be, like involved in any way. I don't know if [omitted] was aware of any complications with - - [omitted] knew the title was in [omitted] name. I'm sure I couldn't - - [name omitted by PYSC] is not dumb. [Omitted] probably was concerned about that, like not wanting to participate by having the title of the car in [omitted] name, but it wasn't like, I think, it wasn't an issue of a degree of close involvedness.
It was and issue of probably having some idea that - - of what we were about to do and not wanting to be involved. But to say not directly involved, my concern there is like saying [omitted] was somehow, like, participating in some noncage-opening way. But the extent of the help was just to, as a personal level, not on an animal liberation level. But, for example, when I called [omitted] and I needed a bus ticket because I didn't have any money - -

Q Right. So [omitted] had an idea, knew what you were going to do with the discussions you had and chose not to come along to be that directly involved in it.

A You say "that directly involved." I just don't know. It just depends what you consider, like directly. You say - -

Q [Omitted] chose not to come along, but did, gave - - knew what you guys were going to do and supported your ideas and your efforts in doing that, right?

A When you say supported ideas and efforts, I think would, as part of, like, these, for example. That's what everyone else in the animal rights group on campus supports the ideas there, but that doesn't necessarily mean that - - [omitted] aided us in, you know, doing things like purchasing materials or researching.
But to say [omitted] had similar ideas, I think we talked about that before, is that all of us in this group kind of had the same ideas about animal suffering.

Q So when you were stopped and called, [omitted] didn't need to ask any questions because [omitted] knew what you were up to?

A [Omitted] knew we were going to do something illegal and on the way to Flordia, releasing mink.

Q [Omitted] arranged to get you the bus ticket in Milwaukee, right?

A Yeah. I don't know if it was Milwaukee or - -

Q Well, you get bus tickets from [omitted], correct?

A Correct.

Q And [omitted] got those tickets in a fake name, right? False name for?

A I believe they used different names, yeah.

EXAMINATION

BY MS LAUTENSCHLAGER:

Q Okay. You told Special Agent Strong that you had used different names so that - - Let's see. Where's the part here?

A I'm not sure - - I'm not sure if we had our I.D. Maybe we gave I.D. and we didn't want to use our names because of maybe not knowing the legal ramifications of being stopped and wanting to leave a trail of, like, where Peter and I were going to go.

Q Do you recall telling Mr. Strong, We went to the bus station where you'd be wired a pair of bus tickets that you could pick up utilizing a code word because you could not use your real names?

A Yeah. Yeah.

Q Do you recall the code word?

A No.

Q Okay.

A No.

Q It was some other name, is that - -

A Yeah. Probably just John Smith. I don't know. Just something.

MR ANDERSON: That was [omitted] idea to do this, right?

THE WITNESS: I'm not necessarily sure that's true.

BY MS LAUTENSCHLAGER

Q Let me start with this. You call [omitted] and [omitted] says, Let me get you some bus tickets?

A No. We call up and say, Can you help us? Can you get us some bus tickets to get out of here? We did not have anything.

Q [Omitted] says yes?

A [Omitted] says yes.

Q Did you ask from where [omitted] is going to get the money none of you guys had?

A You say none of us. [Omitted] had been working. [Omitted] had been working before we left. I never knew [omitted] to be poor, have trouble paying the rent, so some bus tickets I guess I wasn't concerned about. Peter and I didn't have much money when we were stopped. And the car, we spent money on gas and stuff. I'm not sure if we left money in the car.

Q So you didn't ask [omitted] the source of funding for these bus tickets?

A No, I didn't. I kind of assumed [omitted] was paying out of [omitted]’s own pocket because I wouldn't see a need for [omitted] to take a loan from [omitted]’s parents to buy some bus tickets or anything.

Q So you get these bus tickets and you're in, is it Milwaukee, I believe?

A I'm not sure exactly. Sheboygan or - -

Q Milwaukee, okay?

A Okay.

Q It was one of those cities. Did you go anywhere from the time the trooper dropped you off till the time you picked up the bus?

A It might have been Chicago. I don't know. We took a bus from the original place, whatever, Oostburg or Sheboygan or some Wisconsin town - -

Q In eastern Wisconsin?

A Yeah, to, I think it might have been Chicago. Just a big city where there's a Greyhound station and then from there.

Q Okay, Do you know how you got the tickets from the location in Wisconsin to Chicago?

A From the location, I think - - I believe we used possibly our own money to get to a large Greyhound station. Just a short ride, but we needed more money for, like, a trip to get a ticket, for example, to Washington DC, which is where we went.

Q Okay. You got the tickets in Chicago and you go to Washington DC, is that correct?

A That's correct.

Q And when you get there, what do you do?

A When we get there, we decide what we want to do basically. For myself I - - at the time we didn't know what was going to happen with the car. We knew it had been seized and we knew they were going to try to get a search warrant, but we didn't know what would happen if they'd get a search warrant, if there would be charges against us.

Q You figure there might be a possibility of trouble, though, in terms of some sort of legal ramifications for your actions?

A Yeah. Yeah. For myself, what I was really interested in was kind of having some kind of watch what was going to happen and think about it. Take - - You know, just kind of go my own pace and not have it dictated for me in the sense that I wanted to have some distance. You could say be hidden, but the idea was I'd just kind of be able to watch and find out what was going to happen.

Q What did you do then when you got to Washington?

A When I got to Washington, I decided I wanted to actually start traveling in Europe, so I asked [name omitted by PYSC] for help to get a plane ticket to England.

Q And you got a plane ticket to England?

A Correct.

Q And who purchased that?

A [Name omitted by PYSC] did. I asked [omitted] to buy me a plane ticket. I didn't have money. Peter didn't have anything either, so - -

Q Did [Name omitted by PYSC] have money to buy you a plane ticket to England?

A [Omitted] got a plane ticket to London.

Q [Omitted] is starting to cough up a lot of cash for you guys, isn't [omitted]?

A [Omitted] is a good friend. I don't know if it's really that expensive if your best friend comes to you and says, Look, I need a couple hundred dollars or even a thousand dollars or something and they're in real need and they're a very good friend of yours. I don't know that's exactly like, you know, cutting off a limb or breaking the bank to help someone out with a plane ticket who's really in need or perceives themselves in need, so - -

Q Okay. And then, so, [omitted] gets you a plane ticket to England?

A That's correct.

Q Did you stay in Washington for long before you left for England?

A This is an issue I would actually like to talk to my lawyer, if you want to continue here with these questions.

Q We'll get your lawyer. Actually, while Bob is doing that, why don't I ask you some questions along a different line? Do you recall what Peter did when he got to Washington?

A He didn't want to travel outside the country, to leave the country. But, beyond that, I wasn't sure what he was going to do.

Q Did you spend any time with him while in Washington?

A Well, we were discussing, like, a lot along the way what we were going to do and I think it was - - I kind of remember deciding that there was maybe no reason to really directly, like, know where, what the other person is going to be doing.

Q Okay.

A And where they're going, just as long as we kind of knew we didn't want the same thing, so - -

Q Okay.

(Recess at 10:36 a.m., until 10:45 a.m. for the witness to confer with his counsel off the record.)

BY MS LAUTENSCHLAGER:

Q Justin, just a couple more questions. First of all, getting back to where we were, you got to Washington DC, is that correct?

A That's correct.

Q And at that time did you stay in Washington DC for a brief period of time?

A No, not for very long. I had decided I wanted to take a plane out of the country to go to England, or actually just to Europe anywhere. I wasn't too concerned with where, but I had to wait somewhere until, like, the plane ticket would be purchased and the date for the trip would come on.

Q And [name omitted by PYSC] was the person who helped you purchase a plane ticket?

A That's correct.

Q And [omitted] did indeed purchased the ticket?

A [Omitted] purchased it. I didn't have any money, so - -

Q And between the time you caught the plane to Europe and the time you arrived, from the time you arrived in Washington DC until the time you caught the plane to Europe, did you spend some time in the Washington DC area?

A I spent - - [name omitted by PYSC] arranged for me to stay somewhere in Maryland until the time where I would take my plane.

Q Do you recall the mane of the city in Maryland where you stayed?

A No, I do not.

Q Was it near Washington DC?

A I don't know East Coast geography. I think Maryland is next to Washington DC.

Q You didn't stay with [name omitted by Peter Young Support Committee], did you?

A No. [omitted] arranged for a place for me to stay.

Q Did you stay in a home?

A I stayed in a home.

Q Do you recall the people with whom you stayed?

A I would like to speak to my attorney.

Q Do you know anything about the way in which [name omitted by Peter Young Support Committee] made arrangements for you to stay?

A No, I do not,

Q Okay.

MR ANDERSON: Whoever it was that you stayed with, did you talk with them about what had happened, about your trip and - -

THE WITNESS: I would like to talk to my lawyer.

BY MS LAUTENSCHLAGER:

Q Okay. Did you then go from Maryland to New Jersey? Is that correct?

A That's correct.

Q And - -

A I left from - -

Q How did you get from Maryland to New Jersey?

A I was driven.

Q Okay. And when you were driven to New Jersey, you took a plane flight to Europe, is that correct?

A That's correct.

EXAMINATION

BY MR ANDERSON:

Q Do you remember back in 1980 - - I'm sorry - - 1996, you and Peter Young and [name omitted by PYSC] were talked to by a news reporter from a newspaper when you were - -

A Yes. Yes, I do.

Q - - involved in some sort of protest?

A Various times, but I'm sure the one you're talking about is the one in the discovery material.

Q Yeah, the one article in the discovery material?

A It wasn't weird to talk to reporters because that was a lot of the point for Students for Animal Liberation is media and talking to reporters.

Q Right. So you remember having done that, right?

A Various times, yeah.

Q And is it correct that you stated, Economic damage is the ultimate goal. As soon as it's not profitable, these businesses will stop doing it, and you're referring to animal production businesses?

A Yeah. Specifically, actually, in the sense that's kind of a case of reporter sensational line-grabbing. It definitely, like, was a statement I probably said. I'm guessing something along those lines, but I think it related directly to something that occurred nearby, and the reporter had come to ask the group, Student for Animal
Liberation, on campus, like, why is it that people do these thing, and various people in the group, like chipped in.
That was my two cents worth was that's why people do these things, because as soon as, like, the actions are not profitable, they don't do these things because that's - - We were a group that would speak for the actions that were done just based upon our knowledge of reading these materials. And so, regardless of, like, you know, personal beliefs, that question actually was answered in regard to an event that happened nearby that was in the media.

Q Right. But that was your belief and your association with this animal rights movement, right?

A I think it's more than - - I think it would be anyone's belief that if something isn't profitable, that people don't do it. As far as answering that's my belief, I think I just said that.

Q It's not your interest in market forces, but by the actions of the animal rights group that you may be acting on, you're hoping that that dissuades or causes the economic harm that could cause them to go out of business, right?

A Well, at the time I was - - I was a believer in just the idea that, like, animals should not be used that cause them to suffer, and so I think I would have just about agreed with anything that wouldn't cause injury to person or animal. So I would say that was probably true, that you could say that statement. Even though it was meant for applying for some action for someone else, probably could be applied to my beliefs, too.

Q One more thing. In the material you had when you were stopped in Sheboygan, in the address or phone number list was the phone number of [name omitted by PYSC], right?

A That's what I've been told.

Q And you knew [name omitted by PYSC], correct?

A I may have met [omitted]. I did not know - - I do not and do did not know [omitted] personally.

Q Were you at, maybe the year before this, at a protest at UC Berkeley where you and [name omitted by PYSC] were both arrested?

A No.

Q You don't - -

A Not that I recall. I don't think I was ever at a protest at UC Berkeley.

Q Okay. Why did you have [name omitted by PYSC] phone number in your materials?

A I was not aware it was there until I was informed of this a week and a half ago.

Q Who's phone number was that?

A The possibility of that was arrived at when I spoke with the FBI. I probably had the number for maybe some other person, or someone had given it to me as a contact number for them at some point where they were living. But as far as I it being [name omitted by PYSC] number, that was not the reason I had it, if I did. It might have also belonged to someone else. I don't know. I could have it. I just don't know.

Q When you took any of the actions you did, the attacks on farms we talked about, did you contact someone from the Animal Liberation Front, from the press office, the Information Service and tell them that you committed the action?

A No, I did not.

Q Okay. The Animal Liberation Front adopted as one of their actions the attack that you made at the Turbak Mink Farm in South Dakota. Did you know that?

A Not necessarily, no, I didn't.

Q They keep a diary of actions on the website, too, right?

A I think they tend to. It's kind of my belief that they list just about everything that comes out in press articles.

Q They did that then? The fact the Wisconsin farms were attacked would have been listed as an ALF activity, too, wouldn't it?

A I was assuming they were. Probably everything that happened was listed because I think it was all in the media. It was, to my - - It was kind of my assumption that everything - -

Q Had you ever seen the Diary of Actions, this kind of thing?

A I've seen it. I think it's in No Compromise even, and on the internet, so I've see it before.

Q Did you see the Diary of Actions after the events took place you were involved in?

A Sometime between now and then I probably had. I don't know what I took not of.

Q My point is it lists October 17, 1997, Watertown, South Dakota and what happened there, and it registers that as an ALF attack. But, in contrast, the attacks in Independence, Tomahawk and Medford, Wisconsin, the farm, the other farms in the Indictment that we talked about, those are the ones, when you got caught in Wisconsin, and you were associated for certain of those attacks when you were stopped, right?

A Could you repeat that?

Q You were, at the time you were stopped in Sheboygan, they were associating you, connecting you with those raids, those attacks in Wisconsin which is one of the reasons you were stopped, right?

A Yeah. I think they were associating it. I assume, like, with all the raids in South Dakota and Iowa, too. I though that was kind of all connected the area. Arbitrary state borders I assume.

Q You didn't know at the time they had connected you to the South Dakota raid because you got away from that and weren't caught in South Dakota, right?

A I don't know if I was looking at it like that specifically. I was mostly concerned there was going to be some charges made against me. I don't know if I was thinking about the ramifications of being in one place and not in the other.

Q The point I want to get at here is did you communicate with anyone from the Animal Liberation Front or press office or Craig Rosenbraugh, David Barbarath, any of those people to let them know of these actions that you had committed or that you had been stopped in Wisconsin and they should not claim those actions in Wisconsin, to disassociate themselves from those?

A No. I had no contact with these people.

Q So they knew this independently?

A They - - Yeah. They knew it independently.

Q And although I think you said earlier you didn't consider yourself a member, or did you say you did?

A See, I don't know. I guess it was, from my understanding, that this is my personal understanding that I had at the time of what the Animal Liberation Front is, is it's just a name that someone puts on some actions. It's not a real organization and it's just kind of, I don't know, for media purposes or for putting on information. But I guess I never really considered it an organization you could or couldn't be a part of as far as, like, membership organization kind of things go and so I never really concentrated, focused that much on it, whether I did or didn't consider myself.
My interest was more in, like, actually like going out and releasing mink. Not whether or not I would consider myself part of some organization.

Q The Diary of Actions I referred to is Exhibit No. 5. And, but even though you state what you state in regard to your consideration of membership or non-membership, they adopted you as a member of the Animal Liberation Front and used you as somewhat a poster boy for prisoners of war, didn't they?

A See, I would - - I think - - It makes sense, I guess. The way I see it is that if there's a group who believes in releasing, you know, mink and liberating animals and someone gets arrested and charged with this, that they're going to, you know, claim them as, like, you know, one of theirs. If they did or whatever, that at least they're going to support them.
It's like part of the same cause because they make assumptions, if the person is charged with it, even though I at the time, if they did that, I hadn't been found guilty. They - - It seems to make sense to me, I guess, if that's what you're asking.

Q So they established a support group, a support fund for you, right?

A Yeah. I think there's support, like fund out there, just people who never met me who, like, read in the paper that say, oh, such and such a person, some person somewhere was arrested and is charged with such and such, and they have maybe similar beliefs or whatever and so they want to give money, whether or not they've ever met the person, whether or not they - - maybe they - - I don't know. They would have no reason to know what the evidence or the situation is, but just people who hear a name. It could be any name. The just want to support the person. Yeah, those exist.

Q Right. Exhibit No. 7 is a page, some pages from a website that - - your support website?

A That would be the Justin Samuel Support Fund, yes.

Q That's a picture of you?

A That's a picture of me.

Q That's Belgium or something?

A It looks like it. I was probably younger.

Q The support fund, do you know who's in charge of that?

A No. I know - -

Q Are you in communication with them?

A I think my dad actually is running the Justin Samuel Support Fund in the State of Washington. Just like of people want to send money, because he's helping me with, like, the legal cost and so, like, really it's, like, an attempt to get money. So there's a post office box that he had set up in Seattle. That would be it.

Q Legal defense fund?

A Yeah. Keep in mind that this is an issue where it's been an expensive legal thing and if there's people out there who want to give money, they never met me and they just want to give money to help me for - - whether they want to, they believe in the justice of the system and they want to see justice, true justice served or they want to see me get out, whatever their beliefs, they want to give money, and my family and myself are more than happy to accept it.

Q Have you had any communication with anybody else that's running these funds?

A I've received letters from people who consider themselves part of my, like, support group when I was in Belgium. I had my - -

Q Beyond moral support? People - - I'm talking about people that may be in control of the funds? Did you know there's a Justin Samuel Support Campaign Fund in Europe? In London?

A I think there is, yeah. There's jus